You are correct on both counts. The obligation to disclose partial payment policy upon transfer of servicing falls on the party acquiring the servicing. The one exception would be if you are generating the combined goodbye/hello notice instead of separate notices, it would need to be included there.
If you are going to be servicing the loan your partial payment policy is disclosed in the CD.
Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions